Holding United States v. Watson

1 holding

1.1 reasoning
1.2 powell s concurrence
1.3 stewart s concurrence
1.4 marshall s dissent

holding

the court decided case 6-2 majority vote (stevens did not participate in case) arrest of watson , consent , subsequent search of car, did not violate fourth amendment, reversing ninth circut decision.

reasoning

the court relied on (1) well-settled common-law rule warrantless arrest in public place valid if arresting officer had probable cause believe suspect felon; (2) clear consensus among states adhering well-settled common-law rule; (3) expression of judgment of congress such arrest reasonable.  ; (4) regulation, 39 cfr § 232.5(a)(3) (1975), , in identical language, board of governors has exercised power , authorized warrantless arrests. because there probable cause in case believe watson had violated § 1708, inspector , subordinates, in arresting watson, acting strictly in accordance governing statute , regulations. effect of judgment of court of appeals invalidate statute applied in case , applied situations court fails find exigent circumstances justifying warrantless arrest. reverse judgment. ; , (5) because our judgment watson s arrest comported fourth amendment, watson s consent search of car not product of illegal arrest. extent issue of voluntariness of watson s consent resolved on premise arrest illegal, court of appeals in error.

we satisfied in addition remaining factors relied upon court of appeals invalidate watson s consent inadequate demonstrate that, in totality of circumstances, watson s consent not own free , unconstrained choice because ha[d] been overborne , capacity self-determination critically impaired. schneckloth v. bustamonte, 412 u.s. 218, 225 (1973). there no overt act or threat of force against watson proved or claimed. there no promises made him , no indication of more subtle forms of coercion might flaw judgment. had been arrested , in custody, consent given while on public street, not in confines of police station. moreover, fact of custody alone has never been enough in demonstrate coerced confession or consent search. similarly, under schneckloth, absence of proof watson knew withhold consent, though may factor in overall judgment, not given controlling significance. there no indication in record watson newcomer [p425] law, [n14] mentally deficient, or unable in face of custodial arrest exercise free choice. given miranda warnings, , further cautioned results of search of car used against him. persisted in consent.

in these circumstances, hold illegal coercion made out fact of arrest , failure inform arrestee withhold consent not consistent schneckloth , distort voluntariness standard reaffirmed in case.

powell s concurrence

justice lewis powell concurred majority opinion, arguing case definitive holding on constitutionality of warrantless arrest in public place. wrote,

in reversing court of appeals, court concludes nothing in our previous cases involving warrantless arrests supports position of respondent , court of appeals. see, e.g., gerstein v. pugh, 420 u.s. 103, 113 (1975). fair say, think, prior decisions of court have assumed validity of such arrests without addressing in reasoned way analysis advanced respondent. [n1] today s decision [p427] first square holding fourth amendment permits duly authorized law enforcement officer make warrantless arrest in public place though had adequate opportunity procure warrant after developing probable cause arrest.

moreover, constitutional rule permitting felony arrests warrant or in exigent circumstances severely hamper effective law enforcement. police practice requires postponing arrest, after probable cause has been established, in order place suspect under surveillance or otherwise develop further evidence necessary prove guilt jury. [n4] under holding of court of appeals, such additional investigative work imperil entire prosecution. should officers fail obtain warrant initially, , later required unforeseen circumstances arrest no chance procure last-minute warrant, risk court decision subsequent exigency did not excuse failure warrant in interim since first developed probable cause. if officers attempted meet such contingency [p432] procuring warrant had probable cause, , merely held during subsequent investigation, risk court decision warrant had grown stale time used. [n5] law enforcement personnel caught in squeeze ensure validity of arrests obtaining warrant , arresting probable cause existed, thereby foreclosing possibility of gathering vital additional evidence suspect s continued actions.

stewart s concurrence

potter stewart concurred, arguing supreme court should not measure circumstances officer must pass before getting arrest warrant, if crime takes place in public , in broad daylight, arrest in case made upon probable cause in public place in broad daylight. court holds arrest did not violate fourth amendment, , agree. court not decide, nor decide in case, whether or under circumstances officer must obtain warrant before may lawfully enter private place effect arrest. see gerstein v. pugh, 420 u.s. 103, 113 n. 13; coolidge v. new hampshire, 403 u.s. 443, 474-481; davis v. mississippi, 394 u.s. 721, 728; jones v. united states, 357 u.s. 493, 499-500.

marshall s dissent

thurgood marshall dissented, brennan joining, claiming decision gave broad powers police arrest suspects in public without warrant. furthermore, argues cases cited in majority opinion not support ruling, along common law. also, exclaims court did not adequately measure facts in case before deciding. granting police broad powers make warrantless arrests, court today sharply reverses course of our modern decisions construing warrant clause of fourth amendment. court turns next consent search question last dealt in schneckloth [p434] v. bustamonte, 412 u.s. 218 (1973). without acknowledgment or analysis, court extends scope of decision situation expressly reserved in schneckloth, , creates rule inconsistent schneckloth s own analysis. court takes both steps remarkable lack of consideration of either facts of case or constitutional questions deciding. unfortunate not because, in view, court decides constitutional questions wrongly, because consideration have shown first question decided today not raised facts before us, , second question should not resolved here, given present posture of case. respectfully dissent. since, reasons leaves unexpressed, court not take traditional course, constrained express views on issues unnecessarily decides. court reaches conclusion warrant not necessary police officer make arrest in public place, long has probable cause believe felony has been committed, on basis of views of precedent , history. brother powell correctly observes, ante @ 426-427, n. l (concurring), precedent spurious. none of cases cited court squarely confronted issue decided today. moreover, examination of history relied on court shows not support conclusion laid upon it.